A Wisconsin chiropractor recently presented a question on how a patient’s X-rays can be obtained. Although the question, at first, appears fundamental in nature, the analysis of the matter can become relatively complicated after consideration of the State’s evolving approach to delegated services and the interplay of multi-disciplinary practices. On a basic level, most D.C.’s understand that they are allowed to rely on imaging in order to evaluate a patient before a spinal adjustment or manipulation for purposes of determining any contraindications or complicating factors associated with the chiropractic treatment. However, the manner by which the imaging is performed can become more challenging to the chiropractor in light of both statutory and administrative rules. Upon careful evaluation of both, there are basically four (4) means by which the patient’s X-rays can be performed:
- Chiropractor can perfom the imaging themself. D.C.’s are trained in performing x-rays and can perform the imaging within their office. The doctor should feel confident with their knowledge of the task and overall safety and quality of the imaging equipment.
- Chiropractor can DELEGATE the performance of x-rays to a certified radiological technician (CRT) employed by them or associated with their office/business. Wisconsin’s administrative code, Chapter 10, expressly describes the training and capabilities of the CRT to perform x-rays and the ability of chiropractors to delegate such duties to this type of individual. See CHI 10.03. The doctor must ensure that the CRT is properly trained and that there is compliance with CHI 4.04 (proper record keeping, etc.) in making the delegation.
- Chiropractor can ORDER or AUTHORIZE the performance of x-rays from a qualified radiologist or similar health care provider. Wisconsin statutes 462.04 specifically permits a chiropractor, as a “licensed independent practitioner” (See RAD 1.02(12)(d)) to order or authorize the completion of imaging by a radiologist. Some assert that the Wisconsin statute on chiropractic, 446.025(1)(a) restricts such a “referral”. However, an interpretation of that statutory provision, which came into effect with the creation of CT’s and CRT’s, basically addresses situations of delegation since it specifies the CRT and states that such an individual is acting “on behalf of” the chiropractor.
- Chiropractor can REFER the patient to an M.D. or other qualified health care provider, such as an M.D., who can oversee the implementation of X-rays. In this situation, it is important for the D.C. to carefully define or limit the purpose for the referal in recognition that a health care provider refered the care of a patient generally has primary responsibility for the care of that patient within the specified range of that referral.
Under any of these approaches, it remains important for the chiropractor to be very clear with the type of health care provider assigned the task of performing x-rays and the scope or nature of the task assigned to such person. The ability of that individual to then bill for the actual imaging services will be influenced by these important conditions.
COMMUNITY.